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March 2016 » How to Avoid Running Afoul of the...
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Craig P. Ehrlich, JD, and Joanne D. Williams, PhD, CPA
In early 2014, the SEC's enforcement director said that the agency's investigators “were planning to pursue some internal control-related cases,” noting that this area “has been less scrutinized in the past” (Sarah N. Lynch, “SEC Charges QSGI CEO, Former CEO Over Internal Control Failures,” Reuters, July 30, 2014, http://reut.rs/1LjClQE). In this second part of the series, the authors discuss the internal control rules, how the SEC has enforced them against CFOs, and how CFOs can avoid liability.
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